John P. Warner Quoted in Bloomberg BNA Tax Report Article on Treasury Department's Move to Halt Tax Credit Planning Overseas

John P. Warner was quoted in a Bloomberg BNA Tax Report titled, "Potential Impact of Foreign Credit Shutdown: Beyond Apple?" The European Union's recent decision to make Apple accountable for claiming credit for $14.5 billion in taxes has led to "the IRS and Treasury [to take] action to stop U.S. multinationals from improperly claiming the foreign tax credit for taxes they face in a wide range of EU state aid cases—the target of sharp criticism by the U.S.—and other overseas tax audits."

Warner said the [notice] is a “fairly powerful” attack on a technique that he said has been “perfected over time”—one that allows U.S. multinational companies to separate income from taxes paid in ways that pave the way for claiming the foreign credit for taxes paid on income that remains overseas.